HR Policy

The Statement of Human Resources Policy (the “HR Policy”) of the Corporation outlines the guiding principles that govern our approach to the management of all our human capital including direct, indirect and supplier labour.

This HR Policy is neither a contract nor a comprehensive manual; however, it comprises a set of guiding principles for the management of the Company’s human resources, which are implemented through the underlying operational HR policies, processes and procedures, and employment contracts.

Communication

Feronia will have documented policies, processes and procedures that implement the principles of this HR Policy.

We will inform all workers of their rights under national labour and employment law.

We will make our policies clear and understandable to all workers.

Working Conditions and Terms of Employment

The Company will respect the terms of any collective bargaining agreements in force.

The Company will provide reasonable working conditions and terms of employment, at a minimum complying with national labour laws.

Workers’ Organisations

The Company will comply with national laws that recognise the rights of workers to form and join workers’ organisations.

If national laws restrict the right to organise, we will enable the means for workers to bargain collectively and to organise.

If national laws restrict workers’ organisations, we will establish alternative ways for workers to file grievances.

We will not interfere with, or discriminate against, workers who choose to organise.

Worker representatives will be given access to management.

Worker organisations are expected to fairly represent the workforce.

Non-Discrimination and Equality of Opportunity

The Company will hire, promote and compensate workers solely based on their ability to do the job. The Company will not make employment decisions on the basis of personal characteristics(1) which are unrelated to inherent job requirements.

All workers will be given equal access to training, tools and opportunities for advancement.

We will ensure that all workers will be free from harassment by management or other workers.

Positive discrimination may only be allowable in cases where it protects disadvantaged or excluded groups and provides them special opportunities.

Retrenchment

The Company will develop and implement a plan to mitigate (wherever practicable) the adverse impacts of retrenchment if we anticipate a large number of layoffs.

The plan will incorporate non-discrimination principles and include the input of workers, their organisations, where appropriate, the government.

Grievance Mechanism

The Company will establish and maintain a transparent process for workers to express concerns and file grievances, including anonymous complaints.

The Company will ensure that there will be no retaliation or discrimination against those that express grievances.

Management of the Company will treat the grievances seriously and take prompt, appropriate action.

The Company grievance mechanism will not replace other channels as defined by law or collective bargaining agreements.

Child Labour

The Company will not employ workers under the minimum age for employment as defined by national law.

Workers between the minimum age and 18 will not be employed by the Company in hazardous work(2) or work that interferes with their education or development.

All work of persons under the age of 18 will be subject to an appropriate risk assessment and regular monitoring of health, working conditions, and hours of work.

Forced Labour

The Company will not employ forced labour, which consists of any work or service not voluntarily performed that is exacted from an individual under threat of force or penalty. This covers any kind of involuntary or compulsory labour, such as indentured labour, bonded labour, or similar labour-contracting arrangements. The client will not employ trafficked persons(3).

The Company will respect workers’ rights to retain their personal documents and money.

The Company will respect workers’ rights to leave the workplace after work.

The Company will respect workers’ rights to resign.

Occupational Health and Safety

The Company will provide a safe and healthy workplace and working conditions for all employees, contractors, customers and visitors (please refer to Feronia’s ‘Statement of Occupational Health and Safety Policy’, January 2014).

Non-Employee Workers

The Company will extend its labour standards performance policies and procedures to its contractors hired directly or through employment agencies.

The Company will not use contracting as a means of circumventing labour rights and laws.

The Company will monitor contractors, employment and recruitment agencies to verify their adherence to labour rights and laws.

Supply Chain

The Company will extend the principles of this HR Policy as feasible to our suppliers.

The Company will notify its suppliers of the requirements of this HR Policy concerning child labour and forced labour.

The Company will monitor its suppliers’ performance related to the requirements of this HR Policy concerning child labour and forced labour.

1 - Such as gender, race, nationality, ethnic, social and indigenous origin, religion or belief, disability, age, or sexual orientation.

2 - Examples of hazardous work activities include work

with exposure to physical, psychological, or sexual abuse;

underground, underwater, working at heights, or in confined spaces;

with dangerous machinery, equipment, or tools, or involving handling of heavy loads;

in unhealthy environments exposing the worker to hazardous substances, agents, processes, temperatures, noise, or vibration damaging to health; or

under difficult conditions such as long hours, late night, or confinement by employer.

3 - Trafficking in persons is defined as the recruitment, transportation, transfer, harboring, or receipt of persons, by means of the threat or use of force or other forms of coercion, abduction, fraud, deception, abuse of power, or of a position of vulnerability, or of the giving or receiving of payments or benefits to achieve the consent of a person having control over another person, for the purpose of exploitation. Women and children are particularly vulnerable to trafficking practices.